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February 4, 2025 <br />Page 15 <br /> <br />7357-016j <br /> <br />5. The Revised EIR Must Analyze the Projects’ Significant <br />Greenhouse Gas Impacts <br /> <br />The Arroyo Lago Project alone results in significant GHG impacts. These <br />impacts will be significantly increased by GHG emissions from the East Lakes <br />Project. The DEIR concluded that both GHG emissions and transportation impacts <br />from the Arroyo Lago were significant and unavoidable, and failed to analyze GHG <br />and transportation impacts from the East Lakes Project.63 The DEIR asserted that, <br />even with the implementation of mitigation measures MM GHG-1, GHG-2, and MM <br />TRANS-2a and TRANS-2b, the Arroyo Lago Project would still result in significant <br />and unavoidable GHG impacts. SWAPE confirmed that the DEIR’s conclusion that <br />GHG impacts are unavoidable was not supported by substantial evidence. <br />SWAPE’s comments explained that there are additional feasible mitigation <br />measures which could further reduce the Projects’ GHG emissions impacts. The <br />DEIR therefore failed to consider additional measures which could reduce the <br />Project’s GHG emissions impacts to the greatest extent feasible, in violation of <br />CEQA.64 <br /> <br />CEQA requires the lead agency to adopt feasible mitigation measures that <br />will substantially lessen or avoid a project’s potentially significant environmental <br />impacts and describe those mitigation measures in the EIR.65 The lead agency may <br />not make the required CEQA findings regarding a project unless the administrative <br />record demonstrates that it has adopted all feasible mitigation to reduce significant <br />environmental impacts to the greatest extent feasible.66 <br /> <br />SWAPE provided a list of potential GHG mitigation measures that may apply <br />to the Project.67 The City must consider these and any other available feasible GHG <br />mitigation measures that can further reduce the Projects’ significant GHG <br />emissions, and incorporate additional GHG mitigation measures in a new or revised <br />DEIR circulated for public review and comment. <br /> <br /> <br /> <br />63 DEIR, p. ES-18 -19; ES-26. <br />64 SWAPE Comments, p. 10. <br />65 PRC §§§ 21002, 21081(a) 21100(b)(3); CEQA Guidelines § 15126.4. <br />66 Covington v. Great Basin Unified Air Pollution Control Dist. (2019) 43 Cal.App.5th 867, 883. <br />67 SWAPE Comments, pp. 11-12.